Privacy Policy - The Mobile Majority

Privacy Policy

PaeDae, Inc., dba The Mobile Majority (“TMM”, “we”, “us” or “our”), knows that you care about how your information is used and shared, and we take your privacy seriously. Please read the following Privacy Policy
(the “Privacy Policy”). This Privacy Policy applies to TMM’s website located at www.majority.co (collectively, the “TMM Website”) and to TMM’s products and services, including the advertising platform, products and services operated by TMM (collectively, the “TMM Service”).

By accessing and using the TMM Website or using the various websites and applications that participate in the TMM Service, you (“you” or “your”) consent to us processing your information in accordance with this Privacy Policy.

The TMM Website and the TMM Service may link to third party websites or applications. TMM does not control
and is not responsible for such third parties’ privacy practices. Users should consult the privacy policies of such third party websites or applications to learn about such third parties’ privacy practices.

For purposes of this Privacy Policy, “Personally Identifiable Information” or “PII” means any information used or intended to be used to identify a particular individual, including name, address, telephone number, email address, financial account number, and government-issued identifier. “Non-PII” means information not included in the definition of “PII”, including information such as pages or ads visited, clicks on ads, referring domain, visit duration, device type, device identifier, browser type, IP address and operating system.

  1. Use of TMM Website
  2. Cookies and Other Methods for Collection of Information
  3. TMM Service
  4. Opt-Out of Interest-Based Advertising
  5. Data Retention
  6. Third Party Service Providers
  7. Business Transfers
  8. Legal and Regulatory Compliance
  9. Information Processing and Do-Not-Track
  10. Aggregate Information
  11. Security
  12. Minimum Age
  13. Changing Your Newsletter Subscription
  14. Changes to Privacy Policy
  15. Contact

Use of TMM Website

Log Data

As is the case with may other websites, our servers may automatically record Non-PII from visitors to the TMM Website (“Log Data”). This Log Data may include details such as the visitor’s IP address, browser type, referring page and time of visit, and may be used to monitor usage, conduct administration and troubleshooting, and assist in improvements to the TMM Website. We may vary and tailor the content the visitor receives in future visits to the TMM Website based on such visitor’s preferences and activities as determined based upon such Log Data.

Registration and Account Data

If you register to use the TMM Website as a customer (e.g., as an advertiser, agency or publisher), we may ask for and store information you provide such as your email, first name, last name, company name, username, address, phone number, Tax ID, VAT or sales tax registration number, information required for purposes of conducting a credit check if relevant, or any other relevant tax number and credit card information for billing purposes (collectively, “Registration Data”). After you register to use the TMM Website, you may set up advertising campaigns and other account parameters. We may collect information about the manner of your use of the TMM Website, including session length, IP address, time of usage, viewed pages and files, your advertising campaign selections, and other information regarding your use of the TMM Website (collectively with Registration Data, the “Account Data”). This information may be used to provide the TMM Service to you, to conduct internal analysis, account management and maintenance, to perform billing, invoicing and payment functions in connection with your account, to send services-related information, alerts and promotional messages to you, and to maintain and improve the performance of the TMM Website and TMM Service. We may also use this information to offer personalized features, including varying the content that you receive in future visits to the TMM Website based on your preferences and activities. If you provide us with sensitive financial information (such as a credit card number) for payment purposes, we will seek to encrypt the transmission of that information using secure socket layer technology (SSL) or other technology, and utilize a credit card processing company to process your payment information. We may also provide you with the option of adding users to your publisher or advertiser account. When you do so, we will collect the email address of the individual you wish to add. We will then send that individual a one-time email informing them they have been added. If you have been added to an account and wish to no longer have your email address used, you may contact us at privacy@majority.co.

Combination of Log Data, Registration and Account Data

Log Data may be combined with a visitor’s Registration Data and Account Data once the visitor has registered or subsequently logged into the TMM Website. The combined data may be used to provide, monitor and assist in improvements to the TMM Website, and to customize content and advertising displayed to the user on the TMM Website. Log Data, Account Data, Registration Data, and combined data is not sold or rented to third parties. In addition, such information is not shared with third parties except in the case of third party service providers, legal processes and aggregate information, as noted below.

Cookies and Other Methods for Collection of Information

TMM may collect the information noted in this Privacy Policy using the following methods:

  1. cookies, which are small data files that are stored on a visitor’s computer or device.
  2. web beacons or pixels (pieces of code used by websites or third parties to assign online activities to a computer or browser),
  3. server-to-server connections with our partners.

You can set your browser to reject cookies altogether, to reject TMM’s cookies in particular, or to delete cookies (however, this may prevent you from access to certain features of the TMM Website or TMM Service). An End User of the TMM Service may opt-out of interest-based advertising from TMM; please refer to the Section entitled “Opt-Out of Interest-Based Advertising” below.

TMM Service

Types of Information Collected

TMM partners with numerous companies to provide online advertisements to end users of mobile websites, mobile applications (“Apps“) and other online media (“End Users”). As an End User browses the mobile Internet or uses Apps that include references to the TMM Service, the End User’s browser or device may request advertisements from TMM’s system. When TMM receives these requests and/or delivers advertisements to such browser or device, we may collect information about this interaction (as well as any further interaction with the advertisements provided by the TMM Service such as views, clicks, conversions, etc.). This may include, for example: IP address; unique identifiers sent to us from mobile devices, network carriers or data providers; information contained in http headers or other internet transfer protocol signals; de-identified personal information (such as email addresses or usernames that are “hashed” so as to be non-identifiable or non- linkable to an individual); anonymous demographic information such as a user’s gender, age, and income range when not tied or not linkable to personal identifiers; attributes of computer or device usage, such as advertisements clicked, websites and content areas visited; date and time of advertisement request, and advertisement delivery and interaction activities; browser type and version; operating system; language setting; information about or from the presence or use of Apps on a mobile device; and location. Such information may be stored on TMM’s servers. We may also use the GPS location of your device if you have opted to provide it to one of TMM’s publisher or ad exchange partners. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.

End Users may also elect to provide information to TMM, for example, by entering into their information into an advertisement that has been provided by the TMM Service (for example, in order to allow the End User to sign- up for or receive information regarding an advertiser’s product or service or enter a contest or sweepstakes offered by an advertiser). In the event that an End User elects to provide PII under such circumstances, we may collect such PII on behalf of such advertiser or its agency.

In addition, TMM receives information from third parties, such as marketing companies, data compilers and App Developers. This information may include PII, Non-PII, and demographic and behavioral information such as past purchases and interest segments. TMM does not collect or use sensitive information of End Users such as social security numbers, credit card numbers, or banking information.

TMM may also work with partners to collect data across browsers or devices to help predict or infer possible relationships between such browsers and devices, and such insights may be used deliver more relevant advertising across potentially related browsers and devices.

The information collected under this Privacy Policy may be used to provide purchasing opportunities and aggregate reports to advertisers, agencies and publishers who participate in the TMM Service, to schedule, deliver and optimize advertisements, to limit the number of times a specific advertisement is presented to the same browser or device (frequency capping), to provide advertisements only to certain types of mobile devices, to track sales and conversions, to detect and eliminate fraudulent activity, to administer and enhance the TMM Service, and to help TMM display, optimize, target and/or customize advertisements to the interests or preferences of End Users.

The PII received pursuant to this Policy may be shared with the applicable advertiser or its agency on behalf of whom such information was collected. The End User should review the advertiser’s privacy policy to understand how the advertiser will process such PII. TMM may use PII as described in the preceding paragraph, but only after it has been anonymized so as to be non-identifiable to a particular individual. TMM does not sell or rent information it collects about End Users.

TMM may use certain general health-related information in delivering advertisements based on your perceived interest in these topics. This may include information related to general health, wellness, common ailments and illnesses, beauty and fitness, but will not include sensitive health information (such as a user having a certain medical condition like cancer or diabetes). For example, a user who views content related to nutrition might later be shown an ad for dietary products. Similarly, a user who views content related to beauty might later be shown ads related to beauty-related products.

If you have provided your contact information, we may, where permitted by applicable law, send you marketing or promotional offers on behalf of advertisers. You can opt-out of communications as described under “Opt-Out of Interest-Based Advertising” below.

Opt-Out of Interest-Based Advertising

End Users can opt out of interest-based advertising served by TMM. Following an opt-out, TMM’s system will still provide advertisements to the End User. Please note, however, that these advertisements may be less relevant to such End User’s interests. If the End User changes devices, he or she will need to complete the opt-out steps described below on the new device in order to remain opted-out on the new device.

Android 4.3 or earlier:

You can opt out of Android distribution by providing your UDID. To find your UDID:

  • Download the app “Device ID” by redphx from the Google Play Store or other another app that can display “Device ID”. Please use discretion when downloading 3rd party applications.
  • Send your UDID to privacy@majority.co with a request to opt-out.

Android 4.4 or higher:

  • You can opt out of Android distribution by providing your Advertising ID. To find your Advertising ID:
  • Go to “Setting” > “Accounts/Google” > “Ads” where you can copy your Advertising ID.
  • Send your advertising ID to privacy@majority.co with a request to opt-out.

iOS devices:

  • You can opt out of iOS distribution by providing your IDFA (Identifier for Advertising). To find your IDFA:
  • Download the app “The Identifiers app” in the App Store or another app that can display your IDFA. Please use discretion when downloading 3rd party applications.
  • Send your IDFA to privacy@majority.co with a request to opt-out.

You may request to unsubscribe from communications from us by sending an e- mail to privacy@majority.co or by following the unsubscribe instructions contained within the communications you receive from us.

Data Retention

PII and Non-PII are retained for up to 13 months. Aggregated Non-PII is used for reporting and analysis, and may be stored for up to 2 years.

Third Party Service Providers

We retain certain third party service providers to perform functions and services for us. We may share information with these third party service providers, but only to the extent necessary to perform these functions and services, and only pursuant to obligations that are consistent with this Policy.

Business Transfers

In the event of a merger, acquisition, reorganization, change of control, or sale of all or substantially all assets, customer information is typically one of the business assets that is transferred and we may therefore transfer and/or disclose your information to the prospective seller or buyer of such business or assets as a part of such merger, acquisition, reorganization, or sale.

Legal and Regulatory Compliance

We may disclose information when we believe in good faith that such disclosure is legally necessary, or to protect the rights, property, or safety of TMM or others or prevent harm.

Information Processing and Do-Not-Track

Your information may be kept on computers located outside of your state or country, where the privacy laws may not be as protective as those where you live. If you’re located outside the United States and choose to provide your PII to us, we may transfer your PII to the United States and process it there.

TMM does not currently honor do-not-track signals received from Internet browsers. However, you may opt-out of having your information be used for advertisement targeting as described under “Opt-Out of Interest-Based Advertising” above.

Aggregate Information

TMM may share aggregate and anonymous usage statistics regarding the TMM Service with the public or businesses with whom we work. Such aggregated information is not PII. TMM may also use such aggregated information to help TMM improve the design and delivery of the TMM Service and increase its effectiveness.

Security

TMM uses reasonable administrative, technical, personnel and physical measures to safeguard information in its possession against loss, theft and unauthorized use, disclosure or modification. Please note that where we have given you (or where you have chosen) a password that enables you to access the TMM Website or TMM Service, you are responsible for keeping this password confidential. Regardless of the precautions taken by you or by us, “perfect security” does not exist on the Internet. We cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk.

Minimum Age

The TMM Service and TMM Website are not developed for, nor directed at, children under 13. TMM does not knowingly collect or accept PII from anyone under the age of 13. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected PII from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at privacy@majority.co.

Changing Your Newsletter Subscription and Privacy Preferences

TMM may send to registered users and customers certain service and/or account activity-related announcements from time to time. You can unsubscribe from our email newsletters at any time. To do so, you can follow the instructions on the bottom of each newsletter. Advertiser, agency and publisher customers of TMM may also edit their privacy preferences by emailing privacy@majority.co for such purpose. You may also write to TMM at:

2041 Colorado Avenue
Santa Monica, CA 90404
Attn: Privacy

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes in the way we collect and use information or changes in privacy-related laws, regulations, and industry standards. Use of information we collect is subject to the Privacy Policy in effect at the time such information is used.

Contact

If you have any questions or concerns regarding this Privacy Policy, please send us a message to privacy@majority.co or write to us at:

2041 Colorado Avenue
Santa Monica, CA 90404
Attn: Privacy

Last modified: 9/21/2015